File 00 · Pre-revenue · Pre-seed · Independent software
Every figure, traced to the line it came from.
Tonnemark turns a plant's production and energy records into the traced, CN-code-level evidence file that an accredited CBAM verifier reviews. Spreadsheets, scanned invoices, meter readings, process notes — in any language. Every number is linked to the document, page and line it came from. Where two documents disagree, the conflict is surfaced and flagged for a human decision — never silently averaged away.
File 01 · Boundaries
What we do not do.
This section matters as much as the pitch. CBAM assigns each role to a specific actor by law. We build the evidence file. Everything else belongs to someone else — and we say so, up front.
We do not verify
No verification, certification, accreditation or audit — of anything.
That work belongs to verifiers accredited by EU national accreditation bodies. We prepare the file they review; we never sign it.
Delegated Regulation (EU) 2025/2551
We do not file
No declarations into the CBAM Registry.
Filing belongs to the authorised CBAM declarant. The obligation under Regulation (EU) 2023/956 rests with them — not with us, and not with your software vendor.
Regulation (EU) 2023/956
We do not sell files you don't need
If your actuals are at or above the country default, verification saves you nothing.
We say so before you spend anything. The value of verified data is the gap between your default and your real figure — where no gap exists, we will tell you not to buy.
IR (EU) 2025/2620 · IR (EU) 2025/2621
We read the records, extract every number with a source pointer, reconcile conflicts in the open, and deliver a declaration-ready evidence pack: specific embedded emissions per CN code under the CBAM methodology, an explicit assumptions list, and the exact list of artefacts still missing before a verifier can sign.
File 02 · The clock
The Commission's sequence is already running.
Every date below is published. None of them move because a plant is ready — or isn't.
31 December 2026 — the evidence year closes
A trail not built as the year happened cannot be built afterwards.
Jan 2026
Monitoring begins
Operators start monitoring and calculating embedded emissions for the 2026 compliance year.
Apr 2026
Accreditation opens
National accreditation bodies begin CBAM accreditation of verifiers.
Sep 2026
First verification begins
Accredited verifiers register. Verification means a documentation review and a physical site visit at each non-EU installation.
Jan 2027
First reports issued
Verifiers can issue the first verification reports.
30 Sep 2027
First annual declaration due
Covering 2026 imports. What is in the file by then is what gets declared.
File 03 · Cost of defaults
What falling back on defaults costs.
Default values are set above benchmarks on purpose, and carry a rising mark-up. All figures below are declared, mark-up-inclusive values unless stated otherwise.
Default-value mark-up — steel, cement, aluminium, hydrogenIR (EU) 2025/2621
2026
+10%
2027
+20%
From 2028
+30%
Fertilisers capped at +1%. The mark-up sets the default — and the gap to your verified figure widens every year.
India · hot-rolled coil · CN 7208 · BF-BOFtCO₂e per tonne
(mark-up incl.)
India's DRI default: 4.62 against a benchmark of 0.397.
OPIS, 7 Jan 2026 · Fastmarkets, 14 Aug 2026
Unverified HRC — implied tariff
>15% avg. effective, 2026
Fastmarkets' implied average effective tariff on unverified hot-rolled coil.
Fastmarkets, 14 Aug 2026
CBAM certificate price — Commission quarterly averages of EU ETS auction pricesQuoted by quarter
Certificate prices move with EU ETS auctions. Check the Commission's price page for the current quarter before quoting any price.
File 04 · The mechanism
Why the bill is not small this year.
CBAM's cost phases in through the removal of free allocation: 2.5% in 2026, rising to 100% by 2034. It is tempting to conclude the bill is small this year. It isn't. The free-allocation adjustment shields only the benchmark portion of emissions. Everything above the benchmark is chargeable from year one, at full value.
Default values are set above benchmarks on purpose. Which means a producer on defaults is paying the penalty now — not in 2028. And the mark-up that sets those defaults rises from 10% to 20% to 30%, widening the gap every year.
One thing the phase-in does not do is shrink the value of verified data. The free-allocation adjustment is calculated from benchmarks, never from your emissions. On a default declaration it is a single published figure, scaled from the benchmark; on verified actuals it is computed for your installation — your own process, your real precursor chain. Either way it shrinks on the same schedule, for defaults and actuals alike. What carries the certificate price, from year one, is the gap between your default and your verified figure.
- Two conventions exist for the "CBAM factor". This site uses the regulation's: 97.5% of free allocation retained in 2026, falling yearly. IR (EU) 2025/2620, Art. 10a(1a).
- Underlying law: IR (EU) 2025/2620, Articles 2–3 and Annex points 3–4 · Commission CBAM Q&A, 27 May 2026, Q3.8–3.9.
File 05 · Capacity
The people who sign are few.
Verification is done by humans, on site. The counts below are the published picture — quoted as orders of magnitude, not headcounts.
403
Accredited verifiers
Registered in the Union Registry. An order of magnitude — it may include ETS verifiers extending their scope to CBAM.
4,100
Authorised CBAM declarants
As of 1 January 2026 — each one a potential buyer of verifier time.
~12,000
Applicants
Seeking declarant status. IELP World Trade Law, 29 May 2026.
Read these as orders of magnitude. 403 may include ETS verifiers extending scope. We publish the counts and the window — nothing more. We do not claim capacity is booking out, and we do not claim waitlists exist; neither is sourced.
HARD CONSTRAINT — Verification requires a documentation review and a physical site visit at each non-EU installation. That is a hard cost and a hard time slot per installation. A verifier reading a clean, traced, conflict-flagged file spends that slot confirming — not reconstructing.
File 06 · Method
Four steps. No silent guessing.
The output is built to be checked. Every figure in it carries its own provenance.
Send the records
Utility invoices, meter readings, production logs, process descriptions, shift notes. Scans, photos, spreadsheets, PDFs — any language. One real bundle, under NDA. .xlsx.pdfscansphotosany language
Extraction with source pointers
Every number pulled into a structured activity-data record with a pointer to the exact document, page and line it came from. Nothing enters the file untraced. DOC · p. · lnstructured activity data
Reconciliation, not silent guessing
Where two documents disagree, the conflict is surfaced and flagged for a human decision — never silently averaged away. The flag stays in the file, with both sources attached. conflicts surfacedhuman decision
A declaration-ready pack
Specific embedded emissions per CN code under the CBAM methodology, an explicit assumptions list, and the list of exactly which artefacts are still missing before a verifier can sign. per CN codeassumptions listgap list
File 07 · Who it's for
Built for the people who check numbers.
A.
EU authorised CBAM declarants
Who need verified actual data instead of defaults — and who book the verifier's time.
B.
Non-EU steel producers and operators
Iron and steel — first release. Specifically those whose actual emissions sit below their country default, where verification has a payoff.
C.
Traders
Pricing CBAM-inclusive offers and carrying the duty risk on delivered terms.
UK CBAM starts 1 January 2027. Melt-and-pour origin evidence has been mandatory since 1 October 2026 (Regulation (EU) 2026/1384).
File 08 · The offer
Judge the output on your documents — before the January reports are issued.
We are taking a small number of design partners for the 2026 compliance year. Send one real document bundle under NDA and we will produce the evidence pack on it — so you can judge the output, and put it in front of your verifier before the January reports are issued.
or write directly: hello@tonnemark.com